The National Institutes of Health (NIH) has recently released Notice NOT-OD-26-084 to remind the extramural research community of NIH’s longstanding definition of a “foreign component” and related disclosure expectations.
Importantly, NIH clarified that the agency has not changed or expanded the definition of a foreign component, even as oversight of foreign collaborations continues to increase.
Why This Matters
NIH continues to closely monitor foreign collaborations and undisclosed foreign activities associated with federally funded research. Failure to appropriately disclose foreign components may result in additional NIH review, compliance actions, or restrictions on funding activities.
Principal Investigators, departments, and research administrators should carefully review foreign collaborations, publication co-authorship, and project activities to ensure alignment with NIH policy and award terms.
NIH Definition of a “Foreign Component”
According to the NIH Grants Policy Statement, a foreign component is:
“The performance of any significant scientific element or segment of a project outside of the United States, either by the recipient or by a researcher employed by a foreign organization, whether or not grant funds are expended.”
Examples of activities that may constitute a foreign component include:
Involvement of human subjects or animals at a foreign site
Significant foreign travel for data collection, surveying, sampling, or similar activities
Use of foreign facilities, instrumentation, or resources
Receipt of financial support or resources from a foreign entity
Collaborations with investigators at foreign sites anticipated to result in co-authorship
NIH clarified that foreign travel strictly for consultation purposes generally does not constitute a foreign component.
Important Clarification Regarding Foreign Co-Authorship
NIH noted that most instances of foreign co-authorship represent a foreign component, though some limited exceptions may apply where contributions are considered minor or indirect.
Examples provided by NIH include:
Provision of a single reagent that results in co-authorship
Indirect association through a shared domestic collaborator
NIH expects recipients to report foreign co-authorship to the funding Institute or Center as soon as they become aware of it, so NIH can determine whether additional action is necessary.
Review NOFO Restrictions Carefully
Recipients are reminded to closely review the applicable Notice of Funding Opportunity (NOFO) to determine whether foreign components are allowable under a specific program.
Certain NIH programs prohibit foreign components entirely. NIH specifically highlighted the Institutional Development Award (IDeA) program as an example where foreign components are not permitted.
For awards that prohibit foreign components, publications and research activities generally should not include foreign collaborators or co-authors associated with the NIH-funded work.
Publication Acknowledgement and Grant Attribution Reminders
NIH also reiterated federal funding acknowledgement requirements under the Stevens Amendment.
Recipients must ensure that publications and other materials accurately:
Acknowledge NIH support appropriately
Identify the percentage and dollar amount of federally funded project costs, where applicable
Clearly distinguish NIH-supported work from unrelated activities
NIH emphasized that investigators should avoid citing NIH awards that did not actually support the published work, as inaccurate attribution may result in compliance concerns.
Investigators should also ensure that publication affiliations accurately reflect where NIH-funded work was performed.
Additional Information
Full NIH Notice: NOT-OD-26-084
Release Date: May 27, 2026
Questions regarding NIH foreign component disclosures may be directed to the appropriate NIH Institute or Center, or to your DCG Officer for institutional guidance and support.